APPENDIX C.
INFORMATION RECEIVED FROM CHICAGO PUBLIC SCHOOLS
Submission Type Amount / Content
Narrative Response to each
of the Four Issues
The District provided affidavits submitted by both Dr.
Keenan and Mr. Gregory Volan that were responsive to
each of the issues outlined in the Inquiry. Dr. Keenan
responded to Issues 1, 2, and 4 and Mr. Volan responded
to Issue 3.
Affidavits from the Chief
of the Office of Diverse
Learner Supports and
Services (ODLSS), Dr.
Elizabeth Keenan
The District provided affidavits submitted by Dr. Keenan
that provided information including but not limited to the
following topics:
CPS Personnel and Decision-making,
Narrative responses to Issues 1, 2 and 4 generally,
An explanation of data submitted pertaining to
related service provider minutes,
A rebuttal to allegations and positions maintained
by the Advocates which also included
commitments around what CPS could do and
intends to do in the future,
An explanation of the task force that had been
convened under former CEO Forrest Claypool,
and a breakdown of the documents that were being
provided upon request of the Inquiry Team, and
Position vacancies.
Affidavits from a Senior
Assistant General Counsel,
Kathleen Gibbons
The District provided affidavits submitted by Ms.
Kathleen Gibbons that provided information including but
not limited to the following topics: meetings pertaining to
the development of the SSM system, how the SSM system
currently operates, guidance documents developed,
procedural manuals developed, meetings held with the
CTU, trainings conducted, materials at the training, and
data that CPS maintains pertaining to the issues of the
Inquiry.
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Affidavits from the Senior
Budget Manager, Gregory
Volan
The District provided numerous affidavits submitted by
Senior Budget Manager, Gregory Volan that included a
narrative response to Issue 3 generally, and a description
of the budget appeals review process.
CPS Training Materials
The District submitted power point decks and training
materials for case managers and Principals in the areas of
Assistive Technology, ESY, Paraprofessional support,
Separate Day placement, Transportation, and the ODLSS
Procedural Manual.
CPS Procedural Manuals
The District submitted procedural manuals for 2015,
initial and revised, and the 2016 manuals. These
documents were intended to help inform all internal and
external partners, and provide guidance and explain the
special education process.
CPS Guidance Documents
The District provided guidance documents from 2016,
December 2017 (draft version-only), and the guidance
documents from February 2018. More specifically, the
documents include pages related to: Assistive
Technology, Paraprofessional, Related Services, Specific
Learning Disability, and Transportation.
Office of Diverse Learner
Supports and Services
(ODLSS) Organizational
Chart
The District submitted ODLSS Organizational Charts for
2016 and 2017-2018, which outline the various divisions,
and name individuals in more senior levels of
management.
Affidavits from CPS
Administrators
The District submitted two affidavits from CPS
Administrators, one Assistant Principal and one Principal,
who stated their personal knowledge and experiences with
the electronic IEP system, documentation and data
collection requirements placed on personnel, and policies
regarding transportation.
IEP Meeting Data
The District provided the number of IEP meetings that
were held through SY 15-16, SY 16-17, and SY 17-18 (up
3
and through February 15, 2018), with a breakdown of how
many initials / annual meetings there were, how many
revisions meetings there were, and how many in which
there were revisions made without an additional meeting
and a waiver was secured.
The District also provided data of the number of electronic
dissent forms that were submitted from SY 15-16, SY 16-
17, and SY 17-18 (up and through February 16, 2018),
with a breakdown of how many dissent forms were
completed by CPS staff versus how many dissent forms
were completed by non-CPS staff.
Transportation Data
The District provided data on the number of electronic
IEPs with transportation services identified for the student
for SY 15-16, SY 16-17, and SY 17-18 (up and through
February 18, 2018), with a breakdown of how many
students were transportation eligible and how many
students accepted transportation services in each year.
Related Service Provider
Data
The District provided the number of related service
provider IEP minutes that were provided for the
following: SY 15-16, SY 16-17, and SY 17-18 (up and
through February 18, 2018), with a breakdown by related
service provider, including Occupational Therapists,
Physical Therapists, Nurses, Social Workers,
Psychologists, and Speech and Language services. The
chart also provides a breakdown of direct versus indirect
minutes provided by each provider.
The District additionally provided another chart, breaking
each related service provider discipline down and
identifying for SY 15-16, SY 16-17, and SY 17-18, how
many total positions they had in each discipline staffed
and vacant versus how many positions there were open.
Paraprofessional Data
The District provided the number of electronic IEPs with
paraprofessional support for the following: SY 15-16, SY
16-17, and SY 17-18 (up and through February 18, 2018),
with a breakdown of how many IEPs had paraprofessional
support and the total amount of paraprofessional minutes
in IEPs for each year.
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SSM / Impact screenshots
and generated Forms
The District provided hundreds of pages of screenshots of
forms generated by the SSM system and specific pages of
the SSM system itself, including but not limited to pages
concerning Compensatory Education, LRE placement,
paraprofessionals, a list of SSM documents, Help
documents, SSM announcements, updates, trainings,
screenshots related to transportation and related forms,
and screenshots concerning ESY, AT and Augmentative
Communication, accommodations and modifications.
SSM Change Request
Process Flow Chart
The District provided a flowchart that highlights the
compliance monitoring and management of the SSYM
system when there are enhancements or configurations
made. The document also provides a list of key terms to
be mindful of when navigating the change request process,
a step-by-step process of how changes are identified and
implemented, and finally the communication for how
SSM users will be notified of the changes and supported
thereafter.
Budget Presentation by
Senior Budget Manager,
Gregory Volan
The District provided a copy of the presentation given to
the Inquiry Team on February 27, 2018 regarding CPS’
budgeting system that included an overview of the
budgeting process, what is in a school’s budget, how
schools prepare their budgets, and how special education
funding was allocated over the last three years. Mr. Volan
also walked the Inquiry Team through a sample school’s
documentation at the meeting and additionally provided
those documents as well after the meeting concluded.
Budget Review Forms
The District provided an example of the type of forms that
are filled out by the Network Chief upon receiving a
request for an appeal from one of the Chief’s schools.
Dashboard of Appeal
Decisions
The District provided a chart outlining when appeals were
made, by what school, within what network, identifying
the number of special education teachers and
paraprofessionals being requested, the total amount of
funding requested, the status of the review, the decision
summary and the amount ultimately awarded. In addition
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to these statistics, the chart also provides a breakdown of
the racial demographics of the school making the request.
Appeal Decisions 2016-
2017 & 2017-2018
The District provided Review and Decision Reports for
each individual schools’ request and the reports include an
amount request, a description of the request, the
Principal’s justification and the Network Chief’s analysis
/ recommendation. Sometimes the reports also include
relevant data around IEP minutes, student enrollment, and
current funding. The reports also include a summary of the
decision with sometimes a rationale provided.
Agendas and Meetings of
Appeal Committee August
2017 – February 2018
The District also provided copies of their agendas from
their Budget Appeals Review Committee Meetings held
between August 2017 and February 2018 of this current
school year. The agendas provide a network-by-network
break down of the requests being made, capture some
analysis and decisions.
Principal Contract (with
duties)
The District provided a template copy of what the uniform
principal’s performance contract looks like, which
additionally outlines the term, duties of a principal within
CPS, compensation, evaluation criteria, etc.
Job Descriptions for the
Assistant Principal and
District Representative and
Case Manager
Qualifications
The District provided what is available on the “Careers”
page for CPS outlining a description of an Assistant
Principal and District Representative’s duties, and the
qualifications for such positions.
Consultant Documentation
The District provided numerous documents concerning
the task force that had been convened under former CEO
Forrest Claypool for purposes of overseeing the
development of guidelines and protocols to better identify
needs and appropriate services for students with
disabilities. The documents include, but were not limited
to:
Reports generated,
Names of consulting firms or individual
consultants,
Engagement letters,
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A list of CPS staff interviewed by the consultants,
Interview notes,
Documents CPS received from identified
consultants related to special education,
Documents related to meetings convened (e.g.
agendas, meeting minutes, and work streams
identified), where consultants considered the
eligibility of students for special education, related
services, paraprofessional services, transportation
and/or ESY,
Documents related to the implementation of
recommendations generated by any report, and
The payment of consultants.
List of District
Representatives
The District provided a list of District Representations for
SY 16-17 and SY 17-18, broken down by what Network
they were assigned.
Training Materials
The District provided training materials / decks provided
to principals in SY 16-17 around the following topics:
paraprofessional justification forms, ESY, case
management and training materials / decks provided to
case managers in SY 17-18 on SSM changes, a school
profile review, procedures for transfer students, Medicaid
designee updates, agency nurse protocols and scheduling
DIE/504/IEP meetings.
Transportation Documents
The District provided a table of contents, with
accompanying information pertaining to help documents
that were made available to case managers and district
representatives on August 29, 2016, regarding IEP and
504 eligible students. The documents include an
explanation of transportation services in the SSM system
and forms associated with requesting transportation
services for varying needs.
Position Vacancy Data
The District provided a narrative response and data for the
following: SY 15-16, SY 16-17, and SY 17-18, to support
the number of special education vacancies the district had,
broken down by category, (including teachers,
paraprofessionals and related service providers) with an
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accompanying explanation as to how services were
provided in those areas.
IEP Service Minute Report
SY 17-18
The District provided data for SY 17-18 on the total
number of IEP minutes the District had for students with
disabilities up and through February 18, 2018.
Case Study Evaluation
Data
The District provided a chart breaking down of
evaluations completed, eligible and not completed on time
for SY 17-18, up and through February 18, 2018.
The District also provided a chart with eligible evaluations
for SY 17-18 by primary disability category.
Evaluation Extension Data
The District provided a chart for SY 16-17 and SY 17-18
on the number of mutual agreements that were made to
extend evaluation timelines.
Employee Roster
The District provided a copy of their employee roster as
of December 31, 2017.
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INFORMATION RECEIVED FROM ADVOCATES
Submission Type /
Amount
Amount / Content
Statement of Facts
The Advocates submitted a document responsive to all
issues of the Inquiry, titled a “Statement of Facts.” The
document explains the relevance and context of the
submitted documents and further explains issues
addressed in the original Open Letter submitted by the
Advocates.
Parent Affidavit1
The Advocates submitted thirty-four (34) Parent
affidavits. Many of these submissions contained student
Individualized Education Programs (IEPs), emails to /
from the district and school officials, medical
documentation, reports, evaluations, and narratives of the
experiences these students had within CPS and/or the
experiences of the parents themselves in the process of
advocating on behalf of their children.
Special Education
Advocate Affidavit
The Advocates submitted eighteen (18) Advocate
affidavits. Some of these submissions were by licensed
attorneys representing the parent and/or guardian and
student, and some affidavits were submissions by parents
who also consider themselves advocates on behalf of
themselves and other parents. Similarly to the Parent
affidavits, some of these submissions included student
records, and email communications regarding the student.
Special Education Teacher
/ Teacher (generally)
Affidavit
The Advocates submitted fourteen (14) special education
teacher / teacher affidavits. These submissions contain
information about the schools these individuals worked
within, interactions with the administration and/or district
staff, data, and narratives about the students in their
classrooms.
School Social Worker
Affidavit
The Advocates submitted two (2) social worker affidavits
regarding their personal experiences and those of the
students they serve within CPS.
1 Some individuals made submissions in the capacity of both a parent and an advocate. Those submissions have been
counted towards both the total parent and total advocate submissions reflected in this chart.
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School Counselors / Case
Manager Affidavit
The Advocates submitted one (1) school counsel affidavit
regarding their personal experiences and those of the
students they serve within CPS.
School Administrator
(Principal, Assistant
Principal, etc.) Affidavit
The Advocates submitted two (2) administrators, both
Principals, affidavits regarding their personal experiences
and those of the students they serve within CPS.
School Psychologist
Affidavit
The Advocates submitted one (1) school psychologist
affidavit regarding their personal experiences and those of
the students they serve within CPS.
Educare Early Childhood
Center, Disabilities /
Mental Health Manager
Affidavit
The Advocates submitted one (1) affidavit.
Corey H. Monitor
Affidavit
The Advocates submitted one (1) affidavit.
Physician Affidavit
The Advocates submitted two (2) physician affidavits
total. One of a doctor working in school-based clinics and
the other of another physician.
City Committee Hearing
The Inquiry Team listened to and reviewed the video
recording of the City of Chicago Committee on Education
and Child Development Meeting on January 12, 2018.
Documents / Forms related
to Paraprofessional
Justification
The Advocates included the entire paraprofessional
justification form off the SSM, procedure notice,
including paraprofessional justification, student suspected
needs, data collection and current data verification forms,
and data collection template.
Communications between
Advocates and CPS
The Advocates included fourteen (14) communications to
/ from Advocates and CPS regarding concerns with the
procedural manual, policies, procedures, SLD eligibility,
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MTSS data requirements, transportation, client stories,
FOIAs, and settlement agreements.
Access Living Budget
Review of CPS
The Advocates submitted three (3) budget reviews that
were conducted by Access Living on CPS in 2016, 2017,
and 2018.
Communications by the
District to School Staff
The Advocates included one (1) message from former
ODLSS Chief Pat Baccellieri, one (1) MTSS letter from
Baccellieri,
Power Point presentations
to Case Managers
The Advocates included presentations in the following
areas that case managers attended. Presentations on:
Assistive Technology (AT),
Multi Tiered Systems of Support (MTSS),
Eligibility,
Referral,
Paraprofessionals,
Transportation,
Related Services,
Separate Day School,
Specific Learning Disability (SLD), and
Extended School Year (ESY).
Transportation Documents
The Advocates submitted the following documents related
to the transportation issues they have expressed:
OSERS Q & A on Transportation,
CPS’ Transportation Purple Form (old version),
Amended Bulletin No. 9 CPS Transportation,
Testimony to CPS re: transportation,
Letter to parent removing transportation,
Press Release by Legal Council for Health Justice
re: transportation,
Due Process decision concerning removal of
transportation services of a student with
disabilities,
ODLSS letter re: pre-K transportation update,
ODLSS letter to parents re: transportation, and
CPS’ current Blue & Purple Transportation forms.
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District Representative
Review Form
The Advocates submitted what DRs are to review,
generated by the SSM system regarding the items for
which the DR’s involvement was necessary.
Chicago Principals and
Administrators Association
(CPAA) Data, Results, and
Summaries
The Advocates submitted the following documents
developed by the CPAA:
Data summaries,
Survey results,
Narratives on CPS’ delay and denial tactics for
special education funding appeals,
Narratives and analysis on network chiefs backing
or blocking special education budget appeals,
Appeals Process Timelines,
Data Sources for CPS Appeals Discrimination,
CPS Appeals Decisions (FOIA),
Comments on FOIA documents, and
Testimony by CPAA at Illinois House Education
Committee.
Presentations and materials
to Principals
The Advocates submitted the following documents
developed by CPS and provided to Principals as part of
trainings, and Principal Institutes:
Transportation deck,
SLD Eligibility procedures,
Paraprofessional deck,
ESY deck,
Paraprofessional approval, and
Paraprofessional justification form deck.
Office of Diverse Learner
Supports and Services
(ODLSS) Procedural
Manuals
The Advocates submitted the:
ODLSS Procedural Manuals,
Procedure FAQ documents,
Final and Draft versions of procedures related to:
o Transportation,
o SLD,
o Separate Day,
o Related Services,
o Paraprofessionals,
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o AT, and
o ESY.
Guidelines Introduction Letter,
SSM Guidance, and
SSM updates.
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INFORMATION RECEIVED FROM THE STATE BOARD OF EDUCATION
Submission Type Amount / Content
Due Process Decisions
The Inquiry Team found six (6) due process decisions
involving Chicago Public Schools in 2017 and 2018
relevant to the issues being looked into by the Team.
Letters of Findings
The Inquiry Team found fourteen (14) letters of findings
from state complaints involving Chicago Public Schools
from 2016 through 2018 relevant to the issues being
looked into by the Team.
Information from Pam
Jurkoshek, Contractor for
Special Education
Received information regarding CPS’s Maintenance of
Efforts calculations for the last several fiscal years.
Discussions with Timothy
Imler, Division
Administrator for Funding
& Disbursements
Regarding state and federal funding generally. More
specifically, evidence based funding, CPS’ funding of
special education, changes in funding and disbursements
over the last three school years, CPS’ compliance with
reporting requirements, and spending on IDEA-related
personnel.
Discussions with Jason
Hall, Division
Administrator for State
Funding & Forecasting
Regarding CPS’ reporting of state and federal funds,
specifically general state aid and supplemental general
state aid.
Discussions with Deb
Vespa, Division
Administrator for School
Business Services
Regarding student based budgeting methodologies and a
better understanding of school finance.
Discussions with Mark
Schudel, Division
Administrator for Special
Education Administration
Regarding the indicators and focus monitoring done by
ISBE on CPS based on the indicators, data in the School
Report Card, and compliance with IDEA and IDEA’s
reporting requirements.
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Discussions with Annie
Brooks, Division
Supervisor for Title Grant
Administration
Regarding the appropriate use of Title I funds and
reporting requirements on CPS. How CPS utilizes Title I
funds, and the interconnectedness of Title I with special
education funds, if at all.
Discussions with Matt
Ulmer, Division
Administrator for Federal
& State Monitoring
Regarding sources of funding between Title I and special
education funds, and auditing efforts to check this.
Discussions with Heather
Calomese, Executive
Director of Special
Education Services
Division
Regarding pre-K transportation due process matter,
Corey H. monitoring and requirements that CPS was
under, and HSMP reports.
Discussions with Patrick
Payne, Director of Strategy
and Analytics
Regarding an explanation and breakdown of the CPS
special education data provided to us by Sarah Karp on
from 2015 – 2017, an understanding of the employee
position rosters, and additional data typically maintained
by CPS.
Legislative Hearing
The Inquiry Team listened to and reviewed the audio
recording of the Illinois House Elementary and Secondary
Education School Curriculum & Policies Committee
Hearing conducted on January 19, 2018.
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INFORMATION RECEIVED FROM THIRD PARTIES
Submission Type Amount / Content
Office of Diverse Learner
Supports and Services
White Paper Analysis
This was an attachment to CPS’ response to the Advocates
of an analysis done by the District to transparently reflect
on student achievement gaps and the lack of progress in
improving student outcomes for students with disabilities,
and to outline CPS’ plan for reversing this trend, and to
ultimately clarify the future vision.
Parent Affidavits
Parents submitted affidavits on behalf of themselves, their
children, and other parents and students who were
experiencing issues within one of the four areas outlined
in the Inquiry.
Special Education
Personnel Data from
WBEZ Reporter, Sarah
Karp
WBEZ Reporter, Sarah Karp, provided, generally
speaking, special education data from 2015-2017
concerning CPS. More specifically, Ms. Karp provided
the following information to the Inquiry Team including,
but not limited to:
Employee Position Roster March 2016;
Employee Position Roster March 2017;
IEP Minutes Per Service for SY 2015-2016;
IEP Minutes Per Service for SY 2016-2017;
Students with IEPs Eligible for ESY by Primary
Disability 2013-2017;
Related Service Providers, by Provider Type for
SY 13-17; and
Paraprofessionals, by Position Title for SY 13-17.
Current and Former
Teacher Affidavits
Submissions by special education teachers regarding and
including their experiences with administration, district
staff, data, and recounting narratives of their students with
disabilities and concerning issues they have witnessed.
Position Analysis Review
Form
Received a copy of what was then the Office of Special
Education and Supports (OSES) used for submissions of
position requests and in processing and tracking special
education positions.
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Social Worker Affidavit
Submissions of an affidavit regarding their personal
experiences and those of the students they serve within
CPS.